HomeMy WebLinkAbout98-02528
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KATHY ANN WITMER,
Plaintil1'
on behalf oCher minor child,
VIRGINIA MAE YORK,
v.
IN TIlE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, I'ENNSYLV ANIA
NO. 9K- ;) 5l) ~~
CIVIL TERM
THOMAS COMMODORE .IOIINSON,
Defendant
1'lWTlTTION ','ROM ABtlSE
TEMPORARY PROTECTION ORDER
AND NOW, this __'I( I day of May, 1998, upon presentation and wnsideration of the
witbin Petition, and upon finding that the minor child, Virginin Mac York, now residing with her
mother, Kathy Ann Witmer, the plaintill~ at 619 NOI'th I'itt Street, Carlisle, Cumberland County,
Pennsylvania, is in immediate and present danger of abuse fhun the defendant, Thomas
Commodore Johnson, the Ihllowing TempoJ'luy Order is entered
The defendant, Thomas Commodore Johnson, (SSN: lJnknown)(DOH 01/02/73), is an
adult individual residing at 30 Coral Drive, Carlisle, Cumberland County, Pennsylvania, is hereby
enjoined from physically nbusing the minor child, Virginia Mac York, 01' from placing her In fear
ofnhuse.
The defendant is ordered to stllY away lI'om the plaintitl's residence located at 619 NOI'th
Pitt Street, Carlisle, Cumberland County, Pennsylvania, where the minor child resides, which is
not owned 01' leased hy the delendant, and is ordt'red to stay away fi'OIn any residence the minor
child llIay in the future establish for herselr
The detendant is ordered to rell'ain from having any direct or indirect contact with the
minor child including, hut not limited to, telephone, written, and third party communications.
The defendant is enjoined from harassing and stalking the minor child and frOIll harassing
her relatives,
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The defendant is enjoined thun entering the minor child's school and her place of
employment.
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The defendant is er\/oined fl'Om damaging 01' destroying any pl'Oflerty owned jointly by the
parties 01' owned hy the plaintif1~
A viollltlon of thl~ Order may ~ubject the defendant to: i) arrest ullder 2J Pa.C.S,
lt611J; i1) II priVllte crimhllll compllllnt under 2J Pa,C,S. !}61IJ.I; ili) a charge of illdlrect
criminal contempt ullder 2J Pa.C,S. ~6114. puni~bllble by Imprl~onment lip to sb month~
and a nile of $100,00-$1,000.00; and Iv) civil contempt under 23I'a,(:,S. ~6114,1.
This Order shall remain in eflcct until modified 01' terminated by the Court and can be
extended beyond its original expiration date if the Court finds thaI the defendllnt has committed an
act of ahuse or has engaged in II pattern 01' practice that indicates risk of harm to the minor child.
The defelldaut i~ ordered to relinqnl~h to the ~heriff's department any weapons
which he own~ or po~~e~~es. including, bnt not limited to pellet gnns andlol' shotguns. he
hlls used or threlltened to lI~e in an incident of abnse lIgainst tbe pili in tiff. The defendant is
prohibited from acquiring or possessing lIny other weapons for the durlltioll of the Order
and is required to relinquish to the sheriff any firearm license the defendant may po~sess.
The defendant'~ weapons and firearm license mllY be retnrned at the elpiration of the
Protection Order after the defendant has submitted a written reqnest to the Conrt for the
return of the weapons lIlIIl the Conrt has notified the plaintiff of the request and givell the
plaintiff an opportunity to respond. A COllY of this Order shllll hc transmitted to the chief
or head of the police department of the Pennsylvanill State Police (Troop H, Carlisle), and
any other appropriate police depllrtments and the sheriff of Cumberlaud Conuty.
A HEARING SHAll, Of; m:w ON nlls MA TnR ON MA Y I :J. . 1998,
AT .~I: ,-h, (' ,M.. IN COIJRTROOM NO,~. 01<' THE CIIMOERLAND
COUNTY COIJRTHOllSE. CARLISLE. PENNSYLVANIA.
The plaintitl'may proceed without pre-payment of tees pending a fiu1her order after the
hearing.
KATHY ANN WITMER,
Plalntlfl'
on behalf of her minor child,
VIRGINIA MAE YORK,
v.
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, I'ENNSYLV ANIA
NO. 98-_ _
CIVIL TERM
TIIOMAS COMMODORE JOHNSON,
Defendllnt
PROTECTION FROM ABUSE
NOTICE
You have bl'en sued in COlll't. If you wish to defend against the claims set fOl'th In the
following pages, you must take action promptly lifter this Petition, Order and Notice arc served,
by appearing personally or by IItlorney at the hearing scheduled by the Court and presenting to the
Court your defenses 01' objections to the claims set forth against you. You are warned that if you
fail to do so the ('ourt may proceed without you, and II judgment may be entered against you by
the Court without further notice for any money claimed in the I)etition 01' for any other claim or
relief requested by the plaintill'. You may lose money 01' property or other rights important to
you. Any Protectloll Order ~ranted by II Court may be COllsidered III allY subsequent
domestic relations proceedings, including custody lIctions.
Ft~t~S AND COSTS
If the case goes to hearing and the judge gmnts a I'rotection Order, a surcharge 01'$25,00
will be assessed against you, You mllY also be required to pay up to $250.00 to reimburse one of
Legal Services, Inc.'s funding sources for Legal Services, Inc,'s representation of the plaintiff,
You have the rlgbt to be rel"'esented by counsel, You should take this paper to your
lawyer at ollce. If you do Ilot have a lawyer or cannot lIfford one, go to or telephone the
office set forth below to find ont where you call get leglll help, _
CUMBERLAND COUNTY BAR ASSOCIATION
2 LIBERTY AVENUE
CARLISLE, PENNSYLVANIA 17013
TELEPHONE NUMBER (717) 249-3166 01' TOLL FREE: 1-800-990-91l'!l
FAX (717) 249-2663
AMERICANS Wll'lIlJlSABILXnES ACT m' 1990
The Court of Common I'lels of Cumberland County is required by law to comply with the
Americans with Disabilities Act of 1990. For information about accessible facilities and
reasonable accommodations availahle to disabled individuals having business before the court,
please contact our office, All arrangements must be made at least 72 hours prior to any hearing
01' business before the COUl1,
a) Since April 23, 19l)!l, several times the defendant, who is 25 years old, has
driven slowly past the minor child, Virginiu Mae Y OI'k, 15 years old, as she has
been visiting hcr fricnd whosc homc is located on a strect where he has no
husiness, fricnds, 01' rclatives, lInd has driven hy her home n'equently. In addition,
tbe defimdant's fricnd Duvid, who no longcr attends school, has gonc to thc girl's
school, and loitcred about, and the defendant has incitcd his friends, who are the
girl's class mates, to taunt her, clIlI hcr namcs, lInd try to engage her in
conversation ubollt thcir rclationship, exacerbuting her fear of the defendant.
b) On 01' about April 2\, 1998, the defendant picked Virginia up at Iwr school,
argued with her while driving in tlw car, yelled ut her, threatcncd to kill one of her
school mates, and puncbcd her in the face. Aftcr arriving at his home, the
defendant threw Virginia's book bag in the field, and when she went into the house
to telephonc her mother, the defendant grabbed the telephone while she was
talking, and threw it to the noor (liilconnecting the call. As Virginia rail to the
bedroom to use another telephone, the delendant grabbed her by the arm, threw
her to the 11001', kicked her on tbe leg, and choked her. Virginia got away from the
defendant, und ran to the bedroom, but he caught her, threw her onto the bcd, and
punched her about her head, fllce, lInd torso. The defendant threw Virginia's
clothing and personal possessions outside, and threatened to burn them, When
Virginia's mother arrived, she took Virginia to the North Middleton Town~hip
Police Department where she filed a complaint. The defendant was charged with
simple assault, harassment, statutory sexualussault, corruption of minors, indecent
assault, and involuntary deviate sexual intercourse, arrested, and released on his
own recognizance with a condition of his bail that he have no contact with
Virginia, A preliminary hearing is scheduled before District Justice Correal on
June 10, 1998, at I :30 p.m.
The defendant telephoned one of Virginia's school rnate~ at\er this incident
and threatened to have the girl beaten fOl' siding with Virginia
c) In 01' about March 1998, the delendant grabbed Virginia by her arm,
twisted her forearm back and fbrth in his hands causing a burning sensation and
redness on her skin, and pinched her approximately three times on the inside of her
upper arm resulting in bruising and soreness about her arm.
d) In 01' about the summer 1997, the dellmdllnt punched Virginia about her
head,
e) In 01' about fall 1996, tbe defendant hecame angry when Virginia, who was
13 years old, wanted to play with her Barbie dolls rather than watch television with
him, threatened to kill himself, and slashed his ann with a knife. The defendant
was taken to Carlisle Hospital 101' treatment of his seU:inllicted wounds and
required 7-10 stitches. The defendant bears a scar on bis forearm as a result of this
incident.
t) Since appl'Oximately the summer of 1996, the defendant has abused
Virginia in ways including, but not limited In, shoving her about, grabbing her,
slapping, punching, kicking, amI choking her. In addition, the defendant has
restrained Virginia from leaving the residence; refused to take her home to her
mother knowing that her mother bad no means of transportation 10 go to get her;
grabbed her by the hair to restrain her while he punched her about her head and
face; punched walls; driven recklessly, speeding, careening around corners, and
threatening to wreck the car with her in it, and has brandished knives
appror.imately live times and threatened to kill himself The delendant slashed his
wrists several years ago in a suicide attempt and was hospitalized on the
psychiatric ward ofthe Carlisle lIospltal for a period.
S, On or about April 21, 1998, the minor child lell the residence at 30 Coral Drivc,
Carlisle, Cumberland County, I'ennsylvnnia, where she rllsided with the defendant, in order to
avoid further abuse.
b. The plaint in' believes and therefore lIvcrs that her minor child is in immediate and
present danger of abuse from the defendant and that she is in need of protection from such abuse.
7. The plaintill'desires that the defendant be prohibited from having any direct or
indirect contact with her minor child including, but not limited to, telephone and written
communications.
8 The plllintitl'desires that the delendant be enjoined Irom haras!ling and stalking her
minor child, and from harassing the plaint ill' and her relatives
9, The plaintill' desires that the defend lint be restrained from going to the minor
child's school 01' her place ol'employment.
10, The plaintiff'desires that any weapons the defendanf owns or possesses including,
but not limited to, pellet guns and/or shotguns, be confiscated by the Sheriff's Department and
that the defendant be prohibited from acquiring 01' possessing any weapons for the duration of the
Temporary Proteetion Order.
B. EXCUJSIVE POSSESSION
II. The home located at 619 North Pitt Street, Carlisle, Cumberland County,
I'ennsylvania, l'rom which the plaintill' is asking the Court to order the defendant to stay away
from is rented in the name of Kathy Ann Witmer. The defendant resides with his mother at 30
Coral Drive, Carlisle, Cumberland County, Pennsylvania.
C. REIMBURS.~MI<:NT "'OR COST OF' CASE
] 2, The plaintitl' asks that the d(\fendanl be ordered to PflY $250.00 10 Cumberland
County, one of Legal Services, Inc,'s timding sources as reimbursement fhr the cost of litigating
this case, and that the defendant be assessed the $25.00 surcharge and any court costs if the case
goes to hearing.
WHEREFORE, pursuant to the provisiolli. of the "l'l'Ot('ction Ihml Abuse Act" of October
7, 1976,23 P.S, ~6101 Ql ~_cQ" as amended, the plaintill'p1'lIYs this 1I0nornble Court to grant the
following relief:
A. Grant a Temporary Order \lUCSnant to the "Protection from Abuse
Act:"
I, Ordering tbe defendant to refrain from abusing the plaintiff's minor
child or f)'om plllcing her in leal' of abuse.
2, Ordering the defendant to refrain ti'om having any direct or indirect
contact with the minor child including, but not limited to, telephone and
written communications.
3. Ordering tbe defendant to refrain from harassing and stalking the
millOI' child, and from harassing the plaint ill' and/or her relatives.
4. Prohibiting the defendant from going to the minor child's school or
her place of employment.
5, Prohibiting the defendant f1'om damaging 01' destroying any
property owned by the plllinlill'.
6, Ordering the defendant to stay away f)'0I11 the residence of the
minor child located at 619 North Pitt Street, Carlisle, Cumberland County,
Pennsylvania, and any residence the minor child may in the future establish
for herself.
7, Ordering the delendant to rclinquish to thll sherifrs dcpartment any
weapons which hc owns or posseSSllS including, but not limitcd to, pellet
guns and/or shotguns, and prohibiting the defendant Ii'olll acquiring 01'
possl1ssing any weapons fill' thc durlltion of the Temporary Protection
Order.
B. Schedule II heariul( in aecOI'dance with the provisiolls of the
"Protection from Abuse Art," lind, lifter such hearing, eliteI' all order to be
In effect for a period of one year:
I. Ordering the defendant to rt1frain Ihlll1 abusing the plaintill's minor
child, or frolll placing her in fear of abuse.
2. Ordcring the defendant to refrain from having any direct 01' indirect
contact with the minor child including, hut not limited to, telephone and
written communications.
3, Ordering the defendant to refrain ti'om harassing and stalking the
minOl' child and from harassing the plaintifl' lind/or her relatives.
4. Prohibiting the defendant flom going to the minor child's school or
her place of employment.
5, Prohibiting the defendant from damaging or destroying properly
owned by the plaintiffs minOl' child.
6, Ordering the defendant to stay away Ii'om the residence of the
minor child located at 619 North Pitt Street, Carlisle, Cumberland County,
Pennsylvania, and any residence the minor child may in the future establish
for herself.
7, Ordering the defendant to relinquish to the sheriff's department any
weapons which he owns 01' possesses including, but not limited to, pellet
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HEIlLJI.AH
CASE NU I I ')')lj' i!I~~~;;~B I'
COMMUNWEALTH U!" PENNSYLVANIAI
COUNTY 01" CUMBEIlI.ANP
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l.P II NE;U !L.I!J.mtA ~c:nt1J:!\H2QliL._,._.u_
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CUMElEHl.AN[J County, P'H1n"ylvani",. who heing duly BWOI'O aocording
to law, ",aYB. [hp within EJiC,~Tf:!~.I..IOILYflmLltp.\!f!"; .___.....____.___ WaF) 8l!['vecl
up 0 n _.I01Il{SDNI!lQt1.l\i-L C Ol'lJ:1QlJ( 1 Ii E______...._,.__._.....___.______.___._...___....__,....... t he
cteJendant, at __....J..Z.Llil. II[1Ull~;. on the' ,_11J!. day of tllly.______.....__.._,..___..___.
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CAR liS L f;....l'iLJ 1.0 .1..:;1___.____.....__._____..._____________,____._______..._. gj) M B~: R LAN r, ._'
Count.y, PE'nnsyIvania, hy handing tu Imltlll1;i,,,Q1H'!.MDJ'Q~~.2.!J!.tNSCiN_.._.
a tnH? and at.tested copy of the ..J.Bj)n~r;L'LION___E..Il.~~I'LllJllJ;jE;_.__....._ ..'
t agel. II E'r w 1 t II Tf<.I1!:'Jlf\.I\J)}..rHC~l'El,,;..LULl{.._IJHDE H ..._no____.._._....._____._...__.__,
and at thE' ./o""E' t1111e dirE'ct:i.ng [Lis "I,t.ent,,,,, t.o U1G' cont.e"t.s thereof.
Defendant stated that he has no weapons at his residence
and no weapons at any nel.hbors hOllse, pellet gun was taken
previously when deft. was based on pmbation.
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Sworn and subscribed to before 11IE'
thi,s _ 5'~.._ day of '11l<-t ~.__.._,__
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KATHY ANN WITMER,
1'lniuWI'
on behalf of her minor child,
VIROINIA MAE YORK,
IN TilE COURT OF COMMON I'LEAS OF
('UMBI':RI ,AND COUNTY, I'ENNSYLV ANIA
v.
NO. l)l!-2~2" CIVIL TERM
TIIOMAS COMMODOIW JOIINSON,
Detbndnnt
I'ROTECT/ON FROM ABUSE
PROTECTION ORDER
AND NOW, this_1 . day of May, 1998, upon consideration of the Conscnt Agrcement
of thc parties, the fi,lIowing Order is entered.
I, Thc dcfendant, Thomas Commodorc 10hn,mn, is enjoined from physically abusing
the plaintill's minor child, Virginia Mae York, 01' from placing her in leal' of abuse.
2. The defendant is enjoined from having any direct 01' indirect contact with tlm minor
child including, but not limited to, tclephone and written communications.
J. The defendant is ordered to rcfrain from harassing nnd stalking the minor child,
nnd fi'om harnssing the plaintifl' 01' her relatives.
4. The defendant is prohibited from going to the school of the minor child or her
place of employment
5. The defcndant is prohibited fi'om damaging or destroying any property owned by
the minor cbild,
6, The defendant is ordered to stay away from the residence located at 619 North Pitt
Street, ClIrlisle, Cumberland County, Pennsylvania, where the minor child resides with the
plaintiff, and any residence the minor child mny in the fiature establish lor herself.
7. The defendant is ordered to rclinquish to the sherill's dcpllrtment any weapons he
owns 01' possesses including, but not limited to, pellet guns and/or shotguns, and prohibiting the
defendant from acquiring or possessing llny weapons for the duration of the Protection Order,
8, Court costs and fces are waived.
KA'l'IIY ANN WITMER,
Plalntifl'
on behalf of' her minor child,
VIRGINIA MAE YORK,
v.
. IN TIlE COURT OF COMMON I'LEAS OF
. CUMBERLAND COUNTY, PENNSYLVANIA
NO. 98-2528 ('IVIl. TERM
THOMAS COMMODOllE JOIINSON,
Defendant
I'ROTH'lION FROM ABUSE
CONSENT AGREEMENT
'fl--
This Agreement is \,ntered on this.~ day of' MIlY, 1998, hy the plaintiff, Kathy Ann
Witmer, on hehalf of her minor child, Virginia Mac YorK, and the defendant, Thomas
Commodore Johnson, The plaintitl'is represented by Joan Carey of LEGAL SERVICES, INc.;
the defendant is ul1l'epresented but is aware of his right to have an attorney. The parties agree
that the following may be entered as an Order of Court.
I. The detendant, Thomas Commodore Johnson, agrees to ret1'ain from abusing the
plaintitl's minor child, Virginia Mae York, or fromlllacing her in fear of abuse.
2. The defendant agrees not to have any direct or indire(,t contact with the minor
child including, hut not limited to, telephone and written communications.
1 The detendant agrees not to harass and stalk the minor child and not to harass the
plaintiff 01' her relatives.
4. The defendant agrees not to go to the school of the minor child 01' to her place of
employment.
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5, The delendanlagrees not to damage or destroy any property owned by the minor
child,
6, The defendant agrees to stay away Ih,m the residence located at 619 North Pitt
Street, Carlisle, Cumberland County, Pennsylvania, where the minor child resides with the
plaintin~ and any residence the minOl' child may in the future establish for herself.
'.
7. The delendant agrees to rclinquish to tlw sheri II's department IIny wellpons which
he owns or possesses including, hut not limited to pellet guns and/or shotguns, IIgreeN that the
wellPons rcmain in the custody of the Cumherland County Sherill's Department thr the dllmtion
of thc Protection Order, and agrees not to acquire 01' possess any weapons thr the term of the
Protection Ordcr.
8. Thc dcfendant, although entcring into this Agrccment, dOllS not admit the
allegations made in the I'etition.
9, The detendant understllnds lhllt the Protection Order cntered In this mailer will be
in effect fbr a period of one ( I ) ycar al\(l can be extended beyond that timc if the Court tinds that
the defendant has committed an act of abusc 01' has engaged in II pattel'l1 or practil:e that Indicates
risk of harm to the minor child. The detendant understands that this Order will be enforceable in
the same manner as the Court's prior Tempol'HlY Protection Order entered in this casc.
10. Violation ofthc Protection Order may subject the defendant to: i) arrest lindeI' 23
Pa,C.S, ~6113; ii) a private criminal complaint under 23 Pa.e.S. *611.1.1; Iii) a dlflrge of indirect
criminal (:ontempt under 23 PaCS, ~6114, punishable by imprisonment up to six months and a
fine of $ tOO,OO..$1 ,000,00; and iv) civil contempt under 23 PaC.S, ~6114, I.
WHEREFORE, the parties request that a Protection Order be entered to reflect the above
terms.
-K- ~j--L .JL--/tLL.2,,4'-_____
Kllthy ~mer, Plaintill'
-flJlM~ 2J2!~t1fAL__
Virginia ~ae York, Minor (~( IS years old)
1o~t.:iLii~y~~~iif-------
LEGAL SERVICES, 1~~~lm
8 Irvine Row
Carlisle, P A 17013
_LLtI~~~__
Thomas Commod~:hnson, Defendant
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